Wetzel v. Montana Department of Revenue

On January 8, 1976, plaintiffs, a group of recreational vehicle *124(RV) owners from Bozeman, Montana, filed a petition with the Montana Department of Revenue requesting that M.A.C. § 42-2.22 (2) — S22150 be amended. The petition was filed pursuant to section 82-4207, R.C.M. 1947, which allows interested persons to petition an agency requesting the promulgation, amendment or repeal of a rule.

In 1976, the pertinent part of M.A.C. § 42-2.22(2) — S22150 stated:

“. . . ASSESSMENT OF TRAILERS/CAMPERS

“(2) The minimum assessed value of camping and travel trailers shall be the wholesale value (W/S) of…